<Person_1> — never real names, CPFs, or addresses.
Who Must Comply
LGPD applies to:- Any organization processing personal data of individuals located in Brazil
- Regardless of where the organization is headquartered — a US or EU company processing Brazilian data must comply
- When data processing occurs in Brazil, when data subjects are in Brazil, or when data was collected in Brazil
Key LGPD Requirements
Legal Basis for Processing (Art. 7)
Legal Basis for Processing (Art. 7)
Requirement: Personal data processing requires one of 10 legal bases — more than GDPR’s 6. These include consent, legitimate interest, contract performance, legal obligation, research, exercise of rights, health protection, credit protection, and public administration.Risk with AI: Sending personal data to AI providers may lack a clear legal basis, especially when data is used for model training or analytics by the provider.With Blindfold: Since only anonymized tokens reach the AI provider, the legal basis question for the AI provider’s processing is simplified — tokens are not personal data.
Data Subject Rights (Arts. 17-22)
Data Subject Rights (Arts. 17-22)
Requirement: Data subjects have the right to confirmation of processing, access, correction, anonymization of unnecessary data, deletion, data portability, information about third-party sharing, and information about denying consent.With Blindfold: Use
tokenize() for anonymization, redact() for deletion, and detect() to identify what personal data exists. Audit logs document all processing activities for access requests.International Data Transfers (Art. 33)
International Data Transfers (Art. 33)
Requirement: Personal data may only be transferred to countries with adequate protection levels, or with specific guarantees such as Standard Contractual Clauses, binding corporate rules, or specific consent from the data subject.Risk with AI: Most AI providers (OpenAI, Anthropic) process data in the US, which may not meet LGPD adequacy requirements.With Blindfold: Use the EU region (
region="eu") — PII is tokenized before crossing borders. Only anonymized tokens reach the AI provider, which are no longer personal data under LGPD.Data Protection Impact Assessment (Art. 38)
Data Protection Impact Assessment (Art. 38)
Requirement: The ANPD may require a Data Protection Impact Assessment (DPIA / RIPD) when processing activities may create risks to data subjects’ fundamental rights and freedoms.With Blindfold: Blindfold’s audit trail documents all PII detection and anonymization, providing evidence for your DPIA that personal data is protected before AI processing.
Data Protection Officer (Art. 41)
Data Protection Officer (Art. 41)
Requirement: Organizations must appoint a DPO (Encarregado) whose identity and contact information must be publicly disclosed. The Encarregado handles data subject requests, advises on data protection practices, and communicates with the ANPD.With Blindfold: Audit logs and processing records from Blindfold support the DPO’s oversight responsibilities by documenting how personal data is protected in AI workflows.
LGPD vs GDPR
LGPD is closely modeled on the EU’s GDPR, but there are important differences:| Aspect | LGPD | GDPR |
|---|---|---|
| Legal bases for processing | 10 | 6 |
| Supervisory authority | ANPD | National DPAs |
| Maximum fines | 2% of revenue, max R$50M per violation | 4% of revenue or EUR 20M |
| DPO required | Yes (all organizations) | Conditional (specific cases) |
| Cross-border transfers | Adequacy + guarantees | Adequacy + SCCs |
| Effective date | September 2020 | May 2018 |
How Blindfold Maps to LGPD
| LGPD Article | Requirement | Blindfold Feature |
|---|---|---|
| Art. 6 (III) | Data minimization | Tokenization removes PII before AI calls |
| Art. 7 | Legal basis documentation | Audit logs track all processing activities |
| Art. 12 | Anonymization | tokenize(), hash(), redact() |
| Art. 18 (IV) | Right to anonymization | tokenize() + delete mapping |
| Art. 33 | International transfers | EU region + tokenization |
| Art. 46 | Security measures | AES-256 encryption, access controls |
EU Region for LGPD
Since LGPD is closely modeled on GDPR, using Blindfold’s EU region with thegdpr_eu policy provides excellent coverage for LGPD requirements. The gdpr_eu policy detects entity types relevant to both European and Brazilian personal data.
Brazil’s LGPD is closely aligned with GDPR. The
gdpr_eu policy covers the entity types needed for LGPD compliance.gdpr_eu Policy Coverage for LGPD
| Entity Type | LGPD Category | Examples |
|---|---|---|
| Person | Nome (Name) | Maria Silva, Joao Santos |
| Email Address | maria.silva@example.com.br | |
| Phone Number | Telefone | +55 11 98765-4321 |
| Location | Endereco | Sao Paulo, Rua Augusta 123 |
| Date of Birth | Data de nascimento | 15/03/1990 |
| US SSN / National ID | CPF | 123.456.789-09 |
| Credit Card Number | Cartao de credito | 4532-7562-9102-3456 |
| IBAN | Conta bancaria | BR15 0000 0000 0000 1093 2840 814 P2 |
| IP Address | Endereco IP | 189.6.45.123 |
| Organization | Empresa | Empresa XYZ Ltda |
Code Examples
Tokenize Brazilian Personal Data
The most common pattern: protect Brazilian user data before any AI API call.Anonymize for LGPD Art. 12
Usehash() to irreversibly anonymize personal data for analytics or research — satisfying LGPD’s anonymization requirements:
Right to Anonymization (Art. 18)
When a data subject exercises their right to anonymization under Art. 18(IV), tokenize their data and then delete the mapping to make anonymization permanent:Benefits for LGPD Compliance
| Benefit | Details |
|---|---|
| No international data transfer risk | Tokens are not personal data — they can safely cross borders without triggering Art. 33 transfer restrictions |
| Data minimization | Art. 6(III) satisfied automatically — AI providers only receive anonymized tokens |
| Audit trail | Art. 37 record of processing activities — every PII operation is logged with timestamps, entity types, and policies |
| Anonymization | Art. 12 compliance through tokenization and hashing — data subjects’ right to anonymization is supported |
LGPD Compliance Checklist
Identify LGPD applicability
Determine if your AI application processes personal data of individuals in Brazil. LGPD applies regardless of where your organization is located.
Configure Blindfold with EU region
Set
region="eu" in your SDK client. The EU region provides data residency aligned with LGPD requirements.Apply gdpr_eu policy to all processing
Use
policy="gdpr_eu" on all tokenize, redact, encrypt, and hash calls handling Brazilian personal data.Tokenize personal data before AI providers
Always call
blindfold.tokenize() before sending text to any LLM provider. This ensures no real personal data reaches third parties.Maintain audit logs as record of processing
Export audit logs from the Blindfold Dashboard to document your processing activities as required by Art. 37.
Implement data subject rights
Use
detect() for access requests, redact() for deletion, hash() for irreversible anonymization, and tokenize() with discarded mappings for right to anonymization.LGPD is evolving — the ANPD continues to issue new regulations and guidance. Review your compliance posture regularly as new ANPD resolutions are published.
Disclaimer: This documentation provides general information about LGPD compliance requirements. It is not legal advice. Consult with legal counsel familiar with Brazilian data protection law to ensure your specific implementation meets all applicable requirements.